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D R A F T January 4, 2012 and the wastewater applied to land and that is capable of demonstrating that the land application of wastewater complies with the Basin Plan. The Board notes that Order No. R5-2007-0113 contains expanded monitoring requirements that may address this deficiency, although, as noted previously, the monitoring frequency for priority pollutants in the groundwater, pond wastewater, and wastewater used for agricultural irrigation is probably inadequate to meaningfully assess groundwater impacts. The City has several options to address the waste releases from the storage ponds to ensure consistency with Title 27. The City can line the ponds to prevent waste releases to groundwater. Alternatively, the City can improve the quality of wastewater discharged to the ponds in order to ensure that waste releases comply with Basin Plan groundwater objectives. As stated previously, the City is proposing repairs and operational improvements to the Facility that could significantly reduce nitrogen concentrations in the wastewater effluent. These include redirection of the biosolids lagoon supernatant, repair of the leaking municipal influent pipe, and improvements to enhance nitrification and denitrification. Done properly, the expanded monitoring program may be able to assess whether these changes are successful. Operational and design improvements to the onsite ponds can also be evaluated to address groundwater quality impacts. The City should consider enhanced pretreatment requirements for its industrial dischargers. The City may also want to consider either routing its industrial wastewater and industrial and agricultural stormwater runoff through the headworks of the treatment plant or discontinue storing those wastestreams in the storage ponds so that the storage ponds can qualify for the sewage treatment plant exemption from Title 27. In addition, the City can improve the treatment of the municipal effluent applied to land beyond secondary standards. With respect to salt management, the Board notes that Order No. R5-2007-0113 requires the City to prepare a salinity evaluation and minimization plan to address salt sources and to provide annual progress reports on salinity reductions in its discharges to Dredger Cut and the agricultural fields.48 Experience shows that sources of salt in municipal wastewater can be managed and reduced. Likewise, the City can control salinity in the untreated industrial wastewater line through pretreatment requirements. The Board recognizes that elevated salinity in surface water and groundwater throughout the Central Valley is an increasing problem. The State Water Board and the Central Valley Water Board have initiated a 98 Order No. R5-2007-0113,VI.C.3.b. 20.